Daniel Garcia, Jr. v. HHS - other (1994)

This case involves Daniel Garcia, Jr., who suffered vaccine-related injuries. On July 15, 1992, the Special Master issued a decision quantifying damages, including an annual compensation award.

The decision contained a typographical error in the award table, listing the annual compensation for 'Years 42 and beyond' as $50,095 instead of the intended $50,595. The Clerk entered judgment on August 19, 1992, based on this erroneous decision.

Petitioners discovered the error and brought it to the Special Master's attention. On October 27, 1992, the Special Master issued an 'Amended Decision' correcting the typo and purporting to vacate the prior decision.

A new judgment was entered on December 8, 1992. This correction, however, advanced the judgment date, causing petitioners to lose 111 days of compensation they would have otherwise received.

Petitioners sought a lump sum payment for this lost period. The court determined that the Special Master's amended decision and the subsequent judgment of December 8, 1992, were void because the Special Master's jurisdiction had ended upon the entry of the first judgment on August 19, 1992.

The court vacated the December 8, 1992 judgment and reinstated the August 19, 1992 judgment, directing that the typographical error be corrected to $50,595. The case was remanded to the Special Master to determine the amount owing to petitioners.

The court noted that the respondent's position that the delay in payments only affected the borrowing cost of the annuity was incorrect, as the missing payments represented a permanent loss. The public decision does not describe the specific vaccine(s) administered, the date(s) of vaccination, the petitioner's age at vaccination, the specific condition(s) suffered, the clinical story, or the names of any experts.